Fact Witness Travel Request (Domestic Witness Travel)
AUSA, see instructions below.
To: SDNY Victim/Witness Unit
From: AUSA
Date: August 16, 2021
Re: United States v. Ghislaine Maxwell
Court Docket No: 20 Cr. 330 (AN)
USA° No: 2018R01618
Witness-1 Name:
Witness-1 DOB:
Witness-1 Address:
Witness-1 TelNos
Witness-1 e-mail:
Witness-2 Name:
Witness-2 DOB:
Witness-2 Address:
Witness-2 TelNos
Witness-2 e-mail:
Witnesses Needed to Appear in SDNY on Dates: August 25-27, 2021
Witness Needed to Appear for:
Trial ( ) Date:
Grand Jury ( ) Date:
Trial Prep ( X ) Dates: Both witnesses needed for prep on 8/25, 8/26, and 8/27
Estimated Dates Witness will Arrive: August 24, 2021
Depart: August 29, 2021
Is the person a Fact Witness and not an Expert Witness? (Yes/No): _Yes for both_
Current Federal Civilian or Military Employee? (Yes/No): No for both
Is the Witness Facing Criminal Charges? (Yes/No): No for both
Does the Witness Reside Outside the Continental United States? (Yes/No): N f r th
Is this Witness a Victim-Witness? (Yes/No): Yes fo
No fo
Hotel Required? (Yes/No): Yes for both
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Has the Witness advised you of any unusual travel expenses? (Yes/No): Yes
Unusual expenses offact witnesses can include
• special travel arrangements
• care for dependent child or incapacitatedfamily member left at home
• kennelfeesfor pets
• necessary travel companion
• extra baggage (more than one bag)
Please describe the unusual expense:
We are requesting that husband and three minor children travel with and
for this trip. The process of preparing to testify about years of childhood sexual abuse is
extremely traumatizing for and she relies heavily on her family, including her husband
and mother, for emotional support. as struggled significantly with flashbacks and relived
trauma as a result of trial preparation and the significant extent of the sexual abuse she suffered at
the hands of Jeffrey Epstein, so the presence of her husband and mother on this trip is essential for
her wellbeing and ability to prep. her husband, and are the sole caretakers for
minor children. In order for her husband, and to travel together to
New York, where we will prepare both and testify at trial, they will also need
to bring minor children.
The husband's information is below:
Name:
DOB:
Addres
TelNos
e-mail:
Information for minor children is below:
Name:
DOB:
Name:
DOB:
Name:
DOB:
For Victim-Witness Coordinator:
I. (For UEFW other than travel, which must be itemized and approved in advance:) This UEFW
is apparently within VWC approval authority and tentatively approved pending receipt(s) for
UEFW expenses (Yes/No):
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2. Other VWC comments:
VWC Initials and Date:
Instructions to AUSA:
• Use this form for all fact witnesses within the U.S. except government employees and military
personnel, for whom a Request for Armed Forces or Government-Employee Witness should
be used.
• For foreign witnesses, use the International Witness Travel Request. Complete an Early or
Extended stay memo if the witness is being brought in more than 3 business days prior to
court/CI testimony.
• Witnesses may only be brought in under the FEWS appropriation for grand jury testimony that
has been scheduled and where the witness is expected to testify before the grand jury; court
testimony; or preparation for same. Any other witness travel, e.g., for investigative interviews,
must be covered by the investigating component from litigative funds. See Ed Tyrrell.
• See generally DOJ Instruction 1300.01.01 (approved 9/28/2018) and sources referenced
therein.
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